“The loss of analog over-the-air Spanish-language programming could have a significant impact in these areas,” Ferree said in a three-page letter.

KJLA told the FCC that 0.25% of the station’s viewers relied on over-the-air reception. Because Ventura’s Hispanic population is 33.4% and that of Los Angeles is 44.6%, Ferree said, “The loss of analog over-the-air service to even 0.25% of a station’s audience could result in the disenfranchisement of a significant number of persons.”

Had KJLA gained FCC approval, it would have been allowed under the agency’s rules to demand analog-cable carriage of its digital signal.